Memo #
32628

ICI Letter to Treasury/IRS Recommending Retirement Plan Items for Priority Guidance Plan
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[32628]

July 22, 2020 TO: ICI Members
Pension Committee
Pension Operations Advisory Committee SUBJECTS: Pension RE: ICI Letter to Treasury/IRS Recommending Retirement Plan Items for Priority Guidance Plan

 

ICI submitted the attached letter requesting that the Treasury Department and Internal Revenue Service include guidance on certain issues concerning retirement security on their 2020-2021 Priority Guidance Plan.[1] ICI is submitting a separate letter with recommendations concerning regulated investment companies and their shareholders.

The letter asks for guidance on several provisions of the SECURE Act,[2] including:

  • Post-death required minimum distribution rules for designated beneficiaries;
  • Qualified birth/adoption distributions;
  • Pooled Employer Plans and the unified plan rule;
  • Distribution of custodial accounts in a 403(b) plan termination;
  • Consolidated Form 5500 reporting for groups of similar plans;
  • 401(k) eligibility for long-term part-time employees;
  • Increased cap for automatic escalation under the automatic enrollment safe harbor; and
  • Updated LRMs and Forms for IRA providers to reflect SECURE Act changes.

Other items in the letter relate to:

  • Final regulations under Code section 411(a)(11);
  • Expansion of EPCRS self-correction; and
  • Waivers of inadvertent violations of the one-per-year limit on IRA rollovers. 

 

Elena Barone Chism
Associate General Counsel - Retirement Policy

 

Attachment

endnotes

[1] Notice 2020-47 requests public submissions for possible inclusion on the original 2020-2021 Priority Guidance Plan. Notice 2020-47 is available at https://www.irs.gov/pub/irs-drop/n-20-47.pdf.

[2] For more background on the SECURE Act, see ICI Memorandum No. 32118, dated December 20, 2019. Available here: https://www.ici.org/my_ici/memorandum/memo32118.